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of <h1>Article 12 of DTAA Caps Royalty Tax at 10% for Beneficial Owners, Covers Intellectual Property Use.</h1> Article 12 of the Double Taxation Avoidance Agreement (DTAA) between two contracting states addresses the taxation of royalties. Royalties paid to a resident of one state by a resident of the other state may be taxed in both states, but the tax in the state where the royalties arise is capped at 10% if the beneficial owner resides in the other state. Royalties include payments for the use of copyrights, patents, trademarks, and similar intellectual properties. Exceptions apply if the royalties are connected to a permanent establishment in the state where they arise. Special relationships affecting royalty amounts are subject to different provisions.
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